Public Testimony and Comments Regarding the 2022 Proposed Pre-ACA Wellmark, Incorporated Rate Increase
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Public Testimony and Comments
Regarding the 2022 Proposed Pre-ACA
Wellmark, Incorporated
Rate Increase
For Consideration by Commissioner Doug Ommen, Insurance Division of Iowa
Prepared by Sonya Sellmeyer, Consumer Advocacy Officer, Iowa Insurance Division
August 23, 2021I. Background
Iowa Code §505.19 sets forth procedures for health insurance rate increase requests exceeding the
average annual health spending growth rate published by the Centers of Medicare and Medicaid
Services (CMS). The procedures include a requirement that the Consumer Advocate solicit public
comments on the proposed rate increase, provide the comments received by the public on the internet,
and to present the public testimony and comments received to the Commissioner of Insurance for
consideration before a decision is made on the proposed rate increase.
The Consumer Advocate Bureau was notified in June 2021 that Wellmark, Inc. was seeking a proposed
average rate increase of 4.7%. The 4.7% increase varies between plans with a low of 3.6% and a high of
5.9%. The 4.7% average increase applies to various blocks of business exhibiting current loss ratios
exceeding 80%. All of the plans affected are either grandfathered plans or transitional plans for a total
of 38,000 Iowa-covered lives. The proposed rate increase would become effective January 1, 2022, if
approved. As the amount proposed exceeded the most current average annual health spending growth
rate of 5.4%, the Consumer Advocate solicited comments regarding the proposed increase.
II. Actuarial Review
Two separate and independent reviews are conducted to confirm the carrier’s rate change proposal. An
internal review is conducted by the Iowa Insurance Division’s health team (which includes an actuary)
and another review is independently conducted by a consulting actuary (of our choosing) on a contracted
basis. The dual review system has been in place for 13-years.
For any medical insurance rate change proposal, the review involves analyzing the carrier’s experience
(premiums vs. claims), trend (the growth in the cost of the claims caused by unit cost increases along
with utilization increases), and other assumptions to determine if the rate change proposal is actuarially
justified. Both rate review teams employ technically sophisticated processes and algorithms as well as
utilizing forecasting models and scenario testing to gauge the validity and reasonableness of the
proposal. The type of analysis utilized, the formulas and methodology, and overall process have
developed over a period of many years and have been reviewed by other consulting actuaries for
completeness and appropriateness.
The state of Iowa is also considered to have an Effective Rate Review (ERR) program in place by the
Centers for Medicare & Medicaid Services (CMS). Along with the ERR designation by CMS as well as
the process previously described (which predates ERR), the public should be confident that any decision
rendered after this hearing was thoroughly vetted by multiple parties.
Using the actuarial process described, the actuarial teams found the following:
• Past loss ratios for this block have averaged around 85 percent over the last 7-years.
• In the absence of a rate increase for calendar year 2022, the IID projects loss ratios in the range
of 86 to 88 percent depending on the experience base utilized, i.e., 1-yr vs. 2-yrs. vs. 3-yrs, etc.
2
Public Testimony and Comments Regarding the 2022 Proposed Pre-ACA Wellmark, Inc. Rate Increase• IID trend models justify a trend growth rate of at least 7 percent based upon a review of the
PMPM claims and adjusted calendar year loss ratios.
• With the high current loss ratios and the consistent growth of claims, the IID’s 2022 projected
loss ratios range from 82 to 84 percent after the 4.74% rate increase is implemented.
• After adjustments are made to account for taxes, license, and fees in the federally prescribed
medical loss ratio (MLR) formula – the 2022 projected MLR ranges from 86 to 88 percent after
the increase is implemented. (This is achieved using a minimum trend rate – a higher trend rate
is justified)
In the event the MLR dips below 80% with the revised rates (over a 3-year rolling basis),
affected Iowans could receive a rebate under Federal law.
• The average premium increase is around $25/ month, i.e., $557 (2022 projected average
premium) less $532 (current average premium). This is an average based upon all members, all
age groups, all benefit plans, all geographic regions, etc.
Public Comments
The Consumer Advocate has received 29 comments from policyholders and members of the public.
Like most who are subject to proposed rate increases, the comments focused on affordability. Due to
the length of time Wellmark has offered individual policies, many of these policyholders have seen
steady increases from their Wellmark plans over the years. These affected Wellmark pools have been
receiving rate increases every year to every other year which has led to some premiums ballooning from
their original rates and an overall rate increase fatigue. One policyholder commented:
“I am extremely frustrated by the cost of insurance. My husband & I pay $1456.95 each month - that's
over $17,000 a year for our coverage. Neither of us take prescription meds or have any health
conditions. EVERY year our insurance has a HUGE increase - from 2020 to 2021, our monthly
premiums increased $156.50 per month. We both have our own small businesses so we pay the entire
amount. We have both felt a huge financial impact over the last 2 years due to COVID & would love to
see a DECREASE in our premiums. There has to be some DRASTIC CHANGES made. I am tired of
paying for everyone else's poor health. We should be rewarded for having excellent health! We both
make a concerted effort to stay healthy - what can you do as a company to reward us?”
III. Summary
The actuarial summaries show without the rate increase requested Wellmark is facing a possible medical
loss ratio of between 86 and 88%.
The comments received and posted by August 23, 2021, have been included in this testimony report as
required by the Iowa Code section 505.19(3). However, comments may continue to be received until
the Commissioner makes the final decision on the proposed rate increase. Any additional comments
received before the Commissioner’s decision, but after the presentation of the consumer testimony, will
be recorded on the public rate hearing site.
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Public Testimony and Comments Regarding the 2022 Proposed Pre-ACA Wellmark, Inc. Rate IncreaseAttachment A: Wellmark, Inc. 2022 Proposed Rate Increase Comments*
J. M. - Grinnell - August 23, 2021
Rate hikes on health care, at a time like this especially, are disgusting.
___________________________________________________________________________
Norma I. - Muscatine - August 20, 2021
This is getting ridiculous. We already pay $183.58 per week. That’s already $9,546.16 a year and you
want us to pay even more. Not to mention this is just the premium and I’m still paying $48 per office
visit. I had to pay over $200 for an ultrasound I needed. We are already paying In more than what we
are getting in return. Since when has medical insurance companies become for profit businesses??
___________________________________________________________________________
Nick H. - Ames - August 19, 2021
Without warranted stated reasons (other than lining the pockets of shareholders and administrators) for
a massive increase in premiums, Wellmark should be prevented from such an increase. The welfare of
our community depends on it.
___________________________________________________________________________
Donovan B. - Fairfield - August 18, 2021
Despite solid revenues during the COVID-19 pandemic, Wellmark Blue Cross Blue Shield is proposing
upwards of a 21% premium increase for their ACA individual plans for 2022. These skyrocketing
increases impact nearly 60,000 Iowans who rely on these plans. UnitedHealthcare has their own
proposal to increase rates by upwards of 25%! It's up to the Iowa Insurance Division to step in and deny
their proposed premium increases.
Thank you
___________________________________________________________________________
Mary M. - Iowa City - August 18, 2021
I am writing to ask that the Iowa Insurance Division DENY Wellmark's request for a rate increase. This
request has not been justified to the satisfaction of the individuals who will be forced to undergo further
hardship. Doug Ommen must say NO.
___________________________________________________________________________
Linda S. - Newton - August 18, 2021
No one can afford a 21% increase. You can keep this from happening!
___________________________________________________________________________
Tom S. - Des Moines - August 18, 2021
Please deny this viperous, soulless corporation its latest rate increase request. How much is enough?
Thank you
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Public Testimony and Comments Regarding the 2022 Proposed Pre-ACA Wellmark, Inc. Rate Increase___________________________________________________________________________
Jon M. - Nichols - August 17, 2021
Once again its very disgusting how us individuals keep getting terrible rate increases! Something
needs done about this,i pay over 16000 dollars a year! I really don't want to go broke paying these
ridiculous premiums! Make cuts somewhere else!
___________________________________________________________________________
Gail B. - Mt. Vernon - August 17, 2021
I don't get why insurance companies get to pay off their share holders with my money, when I'm on a
limited income. Raising rates doesn't benefit any insured individual. Stock holders, yeah. Get tired of
those guys. Please don't allow BCBS of Iowa to raise their rates. Have them learn to budget like the rest
of us.
___________________________________________________________________________
Jacquelyn S. - West Des Moines - August 16, 2021
The CEO gets huge wage increase each year while I get Hugh raised cost of my supplement insurance
with Well mark or I say Walmart.
The charge way too much.
___________________________________________________________________________
Mindy K. - Cedar Rapids - August 16, 2021
Please stand with Iowans like myself who live on a budget and deny this proposed increase. Wellmark
earned solid revenues. They're doing just fine. Some of us would not be if our premiums were raised.
Thanks for your consideration.
___________________________________________________________________________
Jessica - Des Moines - August 13, 2021
I currently have Wellmark Blue Cross Blue shield, and this increase would increase my healthcare to
where I would no longer be able to cover the premiums and would no longer be able to have health
insurance, which would be more of a burden on the already overtaxed healthcare system. Please do
not increase the premiums and create even more problems to an already flawed healthcare coverage
system!
___________________________________________________________________________
Brian - Woolstock - August 13, 2021
I’m calling to let you know of my displeasure of going ahead and raising my health insurance rates for
like the 15th year in a row. It’s about time to say NO for a change to big companies where they just
kind of push us little people around. I just think that it’s about time to say no for ONCE. Would you
please do that?
It’s getting atrocious about what’s going on. Every year it’s 8, 5, 6, 10%, it just goes on and on and
on. It’s time that something needs to change and say we’ve had enough. I’ve called and called and
called in previous years and it seems like that my opinion is not even being heard.
5
Public Testimony and Comments Regarding the 2022 Proposed Pre-ACA Wellmark, Inc. Rate IncreaseIt’s about time something is done because BlueCross BlueShield is a publicly traded company, and they
are sometimes raising their rates just to show profit to their shareholders. I think that is WRONG. So,
it’s about time something else is done to go ahead and tell the companies that enough is enough. Maybe
there needs to be less wages paid to their top executives to help us little people out here in the country
help pay our bills.
PLEASE, listen to my message. Do something other than just giving them their increases.
I’m getting fed up with it. I am a BlueCross BlueShield subscriber and this has just gone on long
enough. It’s time that something is done to go ahead and say about time to do some slim-trimming on
their part.
I don’t go to the doctor much, but I still have to have health insurance. I am a self-employed person and
it’s just getting tougher and tougher every year. If you could, PLEASE say no.
___________________________________________________________________________
Karen - Floyd - August 10, 2021
You're greed knows no bounds! How do you sleep at night! This needs to stop!
___________________________________________________________________________
Cory - West Des Moines - August 9, 2021
I pay more to Wallmark every year than I utilize in medical costs for me and my family. With the
amount of profit made by the medical insurance industry, there is no reason for another hike in rates like
this. As if we didn’t have enough reason to begin with, this is exactly the reason why we need Medicare
for all. Go ahead and raise rates again and show the American people why insurance in the private
sector, and the greed that comes along with it, needs to go.
___________________________________________________________________________
David - Glenwood - August 9, 2021
Please control price increases.
___________________________________________________________________________
Jane - Ankeny - August 9, 2021
I can't afford to pay a 22% increase in my medical bills. Please deny Wellmark's request but hold them
accountable to provide quality care.
___________________________________________________________________________
Monica - Iowa City - August 9, 2021
Please Do Not approve the rate hike for BC BS. This is far too great of an increase at one time and it
will put in jeopardy many Iowans who are already struggling to pay rent and utilities and feed their
families. Also, if more people are not able to continue their insurance all the people of Iowa will be
paying as we support our state run hospitals. This is a burden on our state. Do Not allow this premium
increase to be approved. Thank you.
___________________________________________________________________________
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Public Testimony and Comments Regarding the 2022 Proposed Pre-ACA Wellmark, Inc. Rate IncreaseJacquelyn - West Des Moines - August 9, 2021
I feel your investment have made money. You should only increase rates less than yearly inflation. Yes
insurance is important but you are pricing yourself out of business. Be kind to humans. You advertise as
a non profit. ????
___________________________________________________________________________
Sally - Des Moines - August 9, 2021
A 21% increase in premiums at a time of a pandemic is unconscionable. You should reject Wellmark
Blue Cross and Blue Shields efforts to increase premiums.
___________________________________________________________________________
Mark - Kingsley - August 6, 2021
As I send my inquiry into how a business can each year ask for and receive a rate increase, I am not
holding my breath as to getting a response. This has been going on how many years. Please have
someone address the situation of rising healthcare costs and insurance companies continually getting a
rate increase for their product yet the premium paid by small businesses and/or individuals never receive
that type of increase for their products or services. When is the last time a rate increase has ever been
denied?
___________________________________________________________________________
Kevin - Omaha, NE - August 2, 2021
I have had this policy through BCBS for 12-15 years and the premiums started out at $110 a month. My
rates have increased from $110 to over $500 a month. This is the first time I have publicly commented
on this. I have been told by a retired agent not to give up this policy, but raising the rates is above and
beyond the amount they should increase. We should by pass this year due to COVID. The
Commissioner has a responsibility to not raise the rates which will help people down the road.
___________________________________________________________________________
Renee - Waterloo - July 24, 2021
We've had this Wellmark Blue Cross Blue Shield policy since 2008. The increases the last few years
have been horrendous with last year being the worst ever. We will pay $14,440.20 for health insurance
in 2021. When this policy started in 2008, it was $3,477.00 for the year. There should not be an
increase at all with how much it was last year. The monthly premiums have been as follows:
2008-$289.75
2009-$314.65
2010-$373.55
2011-$406.25
2012-$445.15
2013-$500.45
2014-$528.95
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Public Testimony and Comments Regarding the 2022 Proposed Pre-ACA Wellmark, Inc. Rate Increase2015-$565.05
2016-$692.05
2017-$737.85
2018-$813.75
2019-$913.65
2020-$1040.55
2021-$1203.35
___________________________________________________________________________
Carol - Sumner - July 24, 2021
Please do not give Wellmark the entire increase they are asking for. Please hold them accountable to
try to reduce their costs. I understand that medical costs have increased. I am a HSA holder so
Wellmark doesn't pay my claims. I don't reach my deductible; however, I continue to have huge
increases in my premiums. I understand about statistics and the pool of insureds you are put into
to. There still has to be a way to keep the premiums down for people on HSA's with high
deductibles. Trust me. HSA insureds are careful about not testing or spending un-necessarily. We
are doing our part. We cannot afford a 5.9% increase. We are already paying a huge portion of our
salary to health insurance premiums. Please consider a smaller percentage increase, and let Wellmark
do what every other company has done - find a way to reduce spending. If they had more competition,
I'm thinking they'd find a way to streamline the bottom line. Thank you for your time.
___________________________________________________________________________
Ryan S. - Sheldon - June 30, 2021
Continuing to raise premiums while the company continues to boast very healthy profits every quarter is
inappropriate. Our income doesn't go up by 11% every year and neither should health insurance. It is
absurd that health insurance costs more than housing and groceries often combined.
___________________________________________________________________________
Carol S. - Atlantic - June 25, 2021
I don’t think the insurance company needs that kind of an increase, especially since last year no
procedures were being done because of Covid. Social Security does not get that amount of increase.
They need to cut expenses somewhere but not expect the individual to keep paying more
each year. When do individuals get a break? I understand people want raises and bonuses but when do
the elderly get that? I don’t know why you say we can leave our comments when the comments
go unheard., Year after year.
I really hope the Iowa insurance commissioner takes all of our comments to heart this year. As
procedures were not done last year because of Covid so expenses should not have increased.
Thanks for reading my comments.
Carol, who LOOSES money each year!!
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Public Testimony and Comments Regarding the 2022 Proposed Pre-ACA Wellmark, Inc. Rate Increase___________________________________________________________________________
Steven B. - Marengo - June 23, 2021
On the request for a base premium rate for Wellmark Blue Cross Blue Shield of Iowa “You say NO!”
Get these rates lower! So people can afford health insurance. I beg you say no!! My health insurance is
already very expensive. And me as all Iowans are fed up with these very high rates. Already Iowans lost
their health insurance because it is too expensive. Please listen to me!
___________________________________________________________________________
Leanne S. - Riverside - June 22, 2021
I am extremely frustrated by the cost of insurance. My husband & I pay $1456.95 each month - that's
over $17,000 a year for our coverage. Neither of us take prescription meds or have any health
conditions. EVERY year our insurance has a HUGE increase - from 2020 to 2021, our
monthly premiums increased $156.50 per month. We both have our own small businesses so we pay the
entire amount. We have both felt a huge financial impact over the last 2 years due to COVID & would
love to see a DECREASE in our premiums. There has to be some DRASTIC CHANGES made. I am
tired of paying for everyone else's poor health. We should be rewarded for having excellent health! We
both make a concerted effort to stay healthy - what can you do as a company to reward us?
___________________________________________________________________________
Mendy R. - Creston - June 21, 2021
I am writing to you in regards of you wanting to increase my premium rates. I am now on Medicare and
on a fixed income. How are people supposed to able to afford health insurance when you want to keep
raising our premiums? You need to look at other ways instead of increasing our premiums. Please, oh
my ...
P.S. I only go to the doctor when I am dieing. So please keep my premiums down low.
*Comments are placed under the health coverage denoted by the consumer.
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